ITR Search | International Tax Review

2007 Tax Package unveiled on Budget Day

Each year, the third Tuesday of September, is Budget Day in the Netherlands. On this year's Budget Day, September 19, the 2007 Tax Package was published. The majority of the proposals included in the 2007 Tax Package will take effect from January 1 2007.

November 01 2006

South Africa makes step forward with binding rulings

The South African tax community has praised the new tax ruling system, but a lack of coverage for transfer pricing and tax avoidance are two disadvantages multinationals may find disappointing.

November 01 2006

Editorial

In hindsight, November 1 2005 turned out to be a significant disappointment for the US tax community. The hand-over of the report of the Advisory Panel on Federal Tax Reform to the Treasury on that day was billed as the beginning of a process of simplification of the Internal Revenue Code.

November 01 2006

Who's worked on the biggest deals

Type of deal Valuer Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition €4.5 billion ($5.64 billion) Nycomed Group (Denmark) Altana Pharma (Germany) KPMG Christian Jänisch, Andre Müller (Germany) Andrew Bjoern (Denmark) Taunus-Treuhand Rolf Kozelka, Peter Werner (Germany)

November 01 2006

Sound Swiss organization on Phonak deal

With its acquisition of competitor GN Resound, Phonak will become the world's largest hearing aid manufacturer. Claire Jones found out how an unusual structuring ensured a low tax cost

November 01 2006

New rules on indirect partial liquidation and transposition

Barbara Brauchli Rohrer Marcel Widrig The deadline for a referendum in respect of the Federal Law on Urgent Adjustments to Corporate Taxation expired unused on October 12 2006. As a result, as of January 1 2007 (federal tax) and January 1 2008 (cantonal tax), new rules will be applicable to indirect partial liquidation cases and so-called transposition cases.

November 01 2006

Real estate: the changing landscape

Legal updates have altered the tax environment for the booming real estate market, reports Carlo Galli of Maisto e Associati

November 01 2006

Proposed tax reforms

Henry An Jin-Young (David) Lee On August 21, the Ministry of Finance & Economy (MOFE) announced its proposed tax reforms. After consulting with various government ministries to finalize the proposals, MOFE will submit the proposals to the National Assembly in October for approval. If approved, the proposed changes will generally become effective from January 2007.

November 01 2006

Editorial

Welcome to the special feature on Italy in the November issue of International Tax Review.

November 01 2006

European Court opposes UK's CFC rules in Cadbury Schweppes

Peter Cussons On September 12, the Grand Chamber of the European Court of Justice handed down its judgment in the Cadbury Schweppes Plc Controlled Foreign Companies (CFC) case. The ECJ has remitted to the UK referring court (the Special Commissioners) the question as to whether the UK motive test can be interpreted so that the UK CFC charge on the UK immediate parent company of an EU (non-UK) lowly taxed (less than 75% of the UK rate ) subsidiary only applies in the case of "wholly artificial arrangements".

November 01 2006

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